https://www.taxtmi.com/caselaws?id=357930 ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal dismissed the assessee's challenge regarding lack of personal hearing before TPO reference, following Vodafone India Services precedent that hearing is required only when Chapter X applicability is contested. On transfer pricing adjustments for export transactions, ITAT favored the assessee, holding that authorities cannot arbitrarily switch from TNMM to CUP method without justification after finding arm's length pricing. For corporate guarantee transactions, the tribunal upheld 1.5% rate as reasonable. Issues regarding section 14A disallowance and section 35(2AB) weighted deduction were remitted to AO for factual verification and fresh consideration. en-us Tue, 06 Mar 2018 00:00:00 +0530 Tue, 06 May 2025 13:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357930 ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal dismissed the assessee's challenge regarding lack of personal hearing before TPO reference, following Vodafone India Services precedent that hearing is required only when Chapter X applicability is contested. On transfer pricing adjustments for export transactions, ITAT favored the assessee, holding that authorities cannot arbitrarily switch from TNMM to CUP method without justification after finding arm's length pricing. For corporate guarantee transactions, the tribunal upheld 1.5% rate as reasonable. Issues regarding section 14A disallowance and section 35(2AB) weighted deduction were remitted to AO for factual verification and fresh consideration. Case-Laws Income Tax Tue, 06 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357930